Daniel Loyola, Jr. v. United States
I. Mr. Loyola pleaded guilty to violating 18 U.S.C. § 922(o), which criminalizes the transfer or possession of a machinegun. On appeal, Mr. Loyola attacked the statute of conviction as unconstitutional. Applying the plain-error standard of review, the Fifth Circuit declared the error alleged to be insufficiently clear. To support the point, it cited a pre-Bruen opinion upholding § 922(o) as constitutional based on the fact machineguns do not receive Second Amendment protections due to their dangerous and unusual nature. The Court's decision in United States v. Rahimi, No. 22-915, could clarify and further explain its holding in New York State Rifle & Pistol Ass'n v. Bruen, and thus impact the Fifth Circuit's plain-error analysis regarding § 922(o)'s constitutionality.
The question presented is:
Whether a ruling in Mr. Rahimi's favor would affect the Fifth Circuit's plain-error analysis concerning the constitutionality of § 922(o).
Whether a ruling in Mr. Rahimi's favor would affect the Fifth Circuit's plain-error analysis concerning the constitutionality of § 922(0)